Fair and Responsible Banking practices continue to be a chief area of concern for prudential supervision stakeholders and enforcement agencies. Financial institutions’ respective Boards of Directors (“Boards”) and senior executives are charged with directing banking staff (e.g., first (“1LOD”), second (“2LOD”), and third (“3LOD”) lines of defense) to develop, implement, and sustain a comprehensive fair lending program in concert with an effective compliance management system (“CMS”). A robust fair lending program should be responsive to an evolving banking industry environment, and forward-looking to mitigate the potential risks of unfair or discriminatory lending practices.

To conduct the fair lending program assessment, Asurity evaluated the Bank’s governance artifacts (e.g., program documentation, policies and procedures, reporting data, etc.) and conducted a series of informational interviews with key management personnel to determine whether the Bank’s practices and processes aligned with fair lending laws and regulations, internal policies and procedures, and other fair and responsible lending best practices. After careful vetting, to the extent any potential issues or gaps were identified, observations and recommendations were drafted and distributed among key stakeholders. After management concurred that the observations were factually accurate, the observations, recommendations, and management responses were included in the final report that withstood robust credible challenge from internal and external stakeholders.